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{{#Wiki_filter:VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA 2326 1 July 27, 2006 United States Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Serial No. 06-585 NLOSlGDM R1 Docket No. 50-281 License No. DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 2 ASME SECTION XI INSERVICE INSPECTION PROGRAM RELIEF REQUEST CMP-007 REGENERATIVE AND RESIDUAL HEAT EXCHANGERS In a letter dated February 9, 2006 (Serial No. 06-057), Virginia Electric and Power Company (Dominion) submitted Relief Request CMP-006, Revision 1, for Surry Power Station Unit 2 pertaining to ASME Section XI Code required inspections on the Regenerative and Residual Heat Exchangers.
{{#Wiki_filter:VIRGINIA   ELECTRIC   AND POWER COMPANY RICHMOND,   VIRGINIA2326 1 July 27, 2006 United States Nuclear Regulatory Commission                   Serial No. 06-585 Attention: Document Control Desk                             NLOSlGDM      R1 Washington, D.C. 20555                                       Docket No. 50-281 License No. DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 2 ASME SECTION XI INSERVICE INSPECTION PROGRAM RELIEF REQUEST CMP-007 REGENERATIVE AND RESIDUAL HEAT EXCHANGERS In a letter dated February 9, 2006 (Serial No. 06-057), Virginia Electric and Power Company (Dominion) submitted Relief Request CMP-006, Revision 1, for Surry Power Station Unit 2 pertaining to ASME Section XI Code required inspections on the Regenerative and Residual Heat Exchangers. NRC approval was requested to use Code Case N-706, Alternative Examination Requirements of Table IWB-2500-1 and Table IWC-2500- 1 for PWR Stainless Steel Residual and Regenerative Heat Exchanger Section XI, Division 1, as an alternative to the requirements in Table IWB 2500-1 for Categories B-B and B-D pertaining to the Regenerative Heat Exchanger and Table IWC 2500-1 for Categories C-A and C-B pertaining to the Residual and Regenerative Heat Exchangers. However, it was subsequently determined that the Code Case requirement "All welds shall have received at least one volumetric examination ..." could not be met for certain components on the Residual and Regenerative Heat Exchangers in that a volumetric examination was never a code requirement. Consequently, verbatim use of Code Case N-706 was not possible for all of the subject items included in the relief request. Discussions were held with the ASME Code Case writers and verification was made that the intent of the Code Case was to cover all of these heat exchanger components. A revision to the Code Case is now in the approval process, which will provide alternative examination requirements for all of the components included in this relief.
NRC approval was requested to use Code Case N-706, Alternative Examination Requirements of Table IWB-2500-1 and Table IWC-2500- 1 for PWR Stainless Steel Residual and Regenerative Heat Exchanger Section XI, Division 1, as an alternative to the requirements in Table IWB 2500-1 for Categories B-B and B-D pertaining to the Regenerative Heat Exchanger and Table IWC 2500-1 for Categories C-A and C-B pertaining to the Residual and Regenerative Heat Exchangers. However, it was subsequently determined that the Code Case requirement "All welds shall have received at least one volumetric examination  
During a subsequent telephone conference call with the NRC, Dominion agreed to submit a separate relief request that did not rely upon Code Case N-706 rather than waiting on approval of the Code Case revision. Therefore, pursuant to 10CFR50.55a(a)(3)(ii), approval is requested to use an alternative to the requirements in Table IWB 2500-1 for Categories 6-6 and B-D associated with the Regenerative Heat Exchanger and Table IWC 2500-1 for Categories C-A and C-B associated with the Residual and Regenerative Heat Exchangers for complying with the code required examination. Compliance with the code requirements would result in a hardship
..." could not be met for certain components on the Residual and Regenerative Heat Exchangers in that a volumetric examination was never a code requirement. Consequently, verbatim use of Code Case N-706 was not possible for all of the subject items included in the relief request. Discussions were held with the ASME Code Case writers and verification was made that the intent of the Code Case was to cover all of these heat exchanger components. A revision to the Code Case is now in the approval process, which will provide alternative examination requirements for all of the components included in this relief. During a subsequent telephone conference call with the NRC, Dominion agreed to submit a separate relief request that did not rely upon Code Case N-706 rather than waiting on approval of the Code Case revision. Therefore, pursuant to 1 OCFR50.55a(a)(3)(ii), approval is requested to use an alternative to the requirements in Table IWB 2500-1 for Categories 6-6 and B-D associated with the Regenerative Heat Exchanger and Table IWC 2500-1 for Categories C-A and C-B associated with the Residual and Regenerative Heat Exchangers for complying with the code required examination. Compliance with the code requirements would result in a hardship Serial No. 06-585 Docket No. 50-281 Page 2 without a compensating increase in quality and safety due to the excessive personnel radiation exposure that would result from the performance of the examinations, as well as the geometric difficulties that would be encountered. The specified alternative and its supporting basis are provided in attached Relief Request CMP-007. Relief Request CMP-007 supercedes in its entirety the previously submitted Relief Request CMP-006, Revision 1. If you have any questions or require additional information, please contact Mr. Gary D. Miller at (804) 273-2771.
 
Very truly yours, .G. T. Bischof u Vice President - Nuclear Engineering Attachment Commitments made in the letter:
Serial No. 06-585 Docket No. 50-281 Page 2 without a compensating increase in quality and safety due to the excessive personnel radiation exposure that would result from the performance of the examinations, as well as the geometric difficulties that would be encountered. The specified alternative and its supporting basis are provided in attached Relief Request CMP-007. Relief Request CMP-007 supercedes in its entirety the previously submitted Relief Request CMP-006, Revision 1.
None cc: U. S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. S. R. Monarque U. S. Nuclear Regulatory Commission One White Flint North 1 1 !j55 Rockville Pike Mail Stop 8H12 Rolckville, Maryland 20852 Mr. N. P. Garrett NR:C Senior Resident Inspector Surry Power Station Mr. R. A. Smith Authorized Nuclear Inspector Surry Power Station Serial No. 06-585 Docket No. 50-281 Attachment Relief Request CMP-007 Virginia Electric and Power Company (Dominion)
If you have any questions or require additional information, please contact Mr. Gary D.
Surry Power Station Unit 2 Serial No. 06-585 Docket No.
Miller at (804) 273-2771.
50-281 Attachment RELIEF REQUEST CMP-007 1. IDENTIFICATION OF COMPONENTS Various welds on the Residual (2-RH-E-1A and 2-RH-E-1B) and Regenerative Heat Exchangers (2-CH-E-3). The welds are: Welds Descri~tion Cateaorv/ltem Class 1 -A0 1 Head Circumferential Weld C-NC1.20 2 1 -A02 Shell Circumferential Weld C-NC1.10 2 1 -A05, 1 -A06, Reinforcing Plate Welds to C-BlC2.31 2 1 -A07,1 -A08 Nozzle and Vessel Welds -- Descri~tion Cateaorvlltem Class 1 -E)01 Head Circumferential Weld C-NC1.20 2 1 -E102 Shell Circumferential Weld C-A/C1 .I 0 2 1 -El05, 1 -B06, Reinforcing Plate Welds to C-BlC2.31 2 1 -ElO7, 1 -BO8 Nozzle and Vessel Page 1 of 11 Serial No. 06-585 Docket No. 50-281 Attachment II. 111. IV. Welds Descri~tion 1-04, 1-1 7, Circumferential Head Welds &l-19 1-03, 1-18, Tubesheet-to-Shell Welds & 1-22 1-06, 1-08, Nozzle-to-Vessel Welds 1-09, 1-11, 1-13, & 1-15 NIR-06, NIR-08, Nozzle Inside Radius Section NIR-09, NIR-11, NIR-13, & NIR-15 1-01, 1-21, Head Circumferential Welds & 1-24 1-02, 1-20, Tubesheet-to-Shell Welds & 1-23 Cateaorvlltem Class B-BlB2.51 1 B-BlB2.80 1 B- DlB3.150 1 B-DlB3.160 C-NC1.20 C-NC1.30 APPLICABLE CODE EDITION AND ADDENDA Su~rry Unit 2 is currently in the Fourth lnservice Inspection Interval under the 1998 Edition through the 2000 Addenda of the ASME Section XI Code. CODE REQUIREMENTS Examination Categories B-B, B-Dl from Table IWB-2500-1 and C-A, C-B from Table IWC-2500-1 require that volumetric or surface examinations be performed on the welds and nozzle inside radius areas listed above. BA.SIS FOR RELIEF The subject welds are shown in Figures 1, 2 and 3 for stainless steel cornponents 2-RH-E-1 A, 2-RH-E-1 B and 2-CH-E-3, respectively.
Very truly yours,
Page 2 of 1 1 Serial No. 06-585 Docket No. 50-281 Attachment The Regenerative Heat Exchanger (2-CH-E-3) provides preheat for the normal charging water flowing into the Reactor Coolant System (RCS). The Residual Heat Exchangers are designed to cool the RCS during plant shut down operations. A feasibility study has been performed within the ASME and prepared by Westinghouse Owner's Group (WOG) project MUHP 5093, Working Group lnservice lnspection Optimization Action 97-01 , ISI-03-06, BC03-338, "Technical Basis for Revision of lnspection Requirements for Regenerative and Residual Heat Exchangers", August, 2004. Technical justification for eliminating the surface and volumetric inspections of the Residual and Regenerative Heat Exlchangers is supported in this report. The components at Surry Power Station (i.~?., 2-RH-E-1A and 1 B; 2-CH-E-3) are typical of the heat exchangers described by fabrication, geometric design, inspection requirements and geometric restrictions.
.G. T. Bischof       u Vice President - Nuclear Engineering Attachment Commitments made in the letter: None cc:     U. S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. S. R. Monarque U. S. Nuclear Regulatory Commission One White Flint North 11!j55 Rockville Pike Mail Stop 8H12 Rolckville, Maryland 20852 Mr. N. P. Garrett NR:C Senior Resident Inspector Surry Power Station Mr. R. A. Smith Authorized Nuclear Inspector Surry Power Station
As stated in the Westinghouse report, these components were designed and installed before the imposition of the inservice inspection requirements by Section XI and are not designed for performance of ultrasonic and surface examination. The small diameter of the vessel and nozzles of the Regenerative Heat Exchanger makes a meaningful ultrasonic examination very time consuming and dose intensive. The physical limitations would substantially diniinish the ability to discriminate flaw indications from geometry existing around the joint. Referring to the Residual Heat Exchangers, interference with the! lower support and interference with inlet and outlet pipes leads to only partial coverage for examination of the head and shell circumferential welds. Furthermore, these components are located in high radiation fields. The estimated personnel dose to perform interval Code inspections on the Regenerative Heat Exchanger is 12.0 man-rem, and it is estimated that 4.5 man- renn would be required to meet the inspection requirements per interval for the Residual Heat Exchanger.
 
In view of the significant dose required to be expended for limited examination providing questionable results, the value of performing the Code required examinations is minimal. Two other factors presented in the Westinghouse report for these components were considered by the ASME committee - flaw tolerance and risk assessment. Fracture evaluations were performed for the components using finite element models and fracture calculations.
Serial No. 06-585 Docket No. 50-281 Attachment Relief Request CMP-007 Virginia Electric and Power Company (Dominion)
It was concluded that the heat exchangers have a large flaw tolerance and that significant leakage would be expected long before any failure occurred. Fatigue crack growth was determined to be extremely slow even in the most highly stressed region. Thus, detailed inspections are not required to ensure heat exchanger integrity.
Surry Power Station Unit 2
Page 3 of 1 1 Serial No. 06-585 Docket No.
 
50-281 Attachment A risk evaluation was performed using the accepted methodology applied for Risk Informed IS1 piping inspection programs. The following conclusions were made: Safety equipment required to respond to the potential event is unaffected.
Serial No. 06-585 Docket No. 50-281 Attachment RELIEF REQUEST CMP-007
Potential for loss of pressure boundary integrity is negligible. No safety analysis margins are changed. Leakage before full break is expected (no core damage consequences associated with leakage).
: 1. IDENTIFICATION OF COMPONENTS Various welds on the Residual (2-RH-E-1A and 2-RH-E-1B) and Regenerative Heat Exchangers (2-CH-E-3). The welds are:
Thus, elimination of the subject inspections would not be expected to result in a significant increase in risk. There have been no through-wall leaks on these components or components of similar design as reported in industry and as discussed in the Westinghouse report. The only related leak in the United States occurred in January 2004 at San Onofre Unit 3 on the letdown line exiting the Regenerative Heat Exchanger. This failure was caused by excessive vibration on the piping line and is not an indlication of failure on the actual heat exchanger.
Welds                 Descri~tion           Cateaorv/ltem         Class 1-A0 1         Head Circumferential Weld     C-NC1.20               2 1-A02         Shell Circumferential Weld   C-NC1.10               2 1-A05, 1-A06, Reinforcing Plate Welds to   C-BlC2.31               2 1-A07,1 -A08   Nozzle and Vessel
All of these welds and the nozzle inner radius section have received some type of nondestructive examination during inservice or preservice inspection. The pressure retaining welds on the Regenerative Heat Exchanger received preservice volumetric examinations as outlined in the attached table. Since the prcservice exams, visual VT-2 examinations have been performed in accordance with NRC approved relief requests.
    - -
Some examinations were limited in coverage but these limitations would again create reduced coverage todlay. See Table 1 for Examination History.
Welds                Descri~tion         Cateaorvlltem         Class 1-E)01         Head Circumferential Weld   C-NC1.20                 2 1-E102         Shell Circumferential Weld   C-A/C1 .I0              2 1-El05, 1-B06, Reinforcing Plate Welds to   C-BlC2.31               2 1-ElO7, 1-BO8   Nozzle and Vessel Page 1 of 11
 
Serial No. 06-585 Docket No. 50-281 Attachment Welds                 Descri~tion               Cateaorvlltem          Class 1-04, 1-17,     Circumferential Head Welds       B-BlB2.51              1
    &l-19 1-03, 1-18,     Tubesheet-to-Shell Welds         B-BlB2.80              1
    & 1-22 1-06, 1-08,     Nozzle-to-Vessel Welds           B-DlB3.150              1 1-09, 1-11, 1-13, & 1-15 NIR-06, NIR-08, Nozzle Inside Radius Section       B-DlB3.160 NIR-09, NIR-11, NIR-13, & NIR-15 1-01, 1-21,     Head Circumferential Welds         C-NC1.20
    & 1-24 1-02, 1-20,     Tubesheet-to-Shell Welds           C-NC1.30
    & 1-23 II. APPLICABLE CODE EDITION AND ADDENDA Su~rryUnit 2 is currently in the Fourth lnservice Inspection Interval under the 1998 Edition through the 2000 Addenda of the ASME Section XI Code.
111. CODE REQUIREMENTS Examination Categories B-B, B-Dl from Table IWB-2500-1 and C-A, C-B from Table IWC-2500-1 require that volumetric or surface examinations be performed on the welds and nozzle inside radius areas listed above.
IV. BA.SISFOR RELIEF The subject welds are shown in Figures 1, 2 and 3 for stainless steel cornponents 2-RH-E-1A, 2-RH-E-1B and 2-CH-E-3, respectively.
Page 2 of 11
 
Serial No. 06-585 Docket No. 50-281 Attachment The Regenerative Heat Exchanger (2-CH-E-3) provides preheat for the normal charging water flowing into the Reactor Coolant System (RCS). The Residual Heat Exchangers are designed to cool the RCS during plant shut down operations.
A feasibility study has been performed within the ASME and prepared by Westinghouse Owner's Group (WOG) project MUHP 5093, Working Group lnservice lnspection Optimization Action 97-01, ISI-03-06, BC03-338, "Technical Basis for Revision of lnspection Requirements for Regenerative and Residual Heat Exchangers", August, 2004. Technical justification for eliminating the surface and volumetric inspections of the Residual and Regenerative Heat Exlchangers is supported in this report. The components at Surry Power Station (i.~?.,
2-RH-E-1A and 1B; 2-CH-E-3) are typical of the heat exchangers described by fabrication, geometric design, inspection requirements and geometric restrictions.
As stated in the Westinghouse report, these components were designed and installed before the imposition of the inservice inspection requirements by Section XI and are not designed for performance of ultrasonic and surface examination. The small diameter of the vessel and nozzles of the Regenerative Heat Exchanger makes a meaningful ultrasonic examination very time consuming and dose intensive. The physical limitations would substantially diniinish the ability to discriminate flaw indications from geometry existing around the joint. Referring to the Residual Heat Exchangers, interference with the! lower support and interference with inlet and outlet pipes leads to only partial coverage for examination of the head and shell circumferential welds.
Furthermore, these components are located in high radiation fields. The estimated personnel dose to perform interval Code inspections on the Regenerative Heat Exchanger is 12.0 man-rem, and it is estimated that 4.5 man-renn would be required to meet the inspection requirements per interval for the Residual Heat Exchanger. In view of the significant dose required to be expended for limited examination providing questionable results, the value of performing the Code required examinations is minimal.
Two other factors presented in the Westinghouse report for these components were considered by the ASME committee - flaw tolerance and risk assessment.
Fracture evaluations were performed for the components using finite element models and fracture calculations. It was concluded that the heat exchangers have a large flaw tolerance and that significant leakage would be expected long before any failure occurred. Fatigue crack growth was determined to be extremely slow even in the most highly stressed region. Thus, detailed inspections are not required to ensure heat exchanger integrity.
Page 3 of 11
 
Serial No. 06-585 Docket No. 50-281 Attachment A risk evaluation was performed using the accepted methodology applied for Risk Informed IS1 piping inspection programs. The following conclusions were made:
Safety equipment required to respond to the potential event is unaffected.
Potential for loss of pressure boundary integrity is negligible.
No safety analysis margins are changed.
Leakage before full break is expected (no core damage consequences associated with leakage).
Thus, elimination of the subject inspections would not be expected to result in a significant increase in risk.
There have been no through-wall leaks on these components or components of similar design as reported in industry and as discussed in the Westinghouse report. The only related leak in the United States occurred in January 2004 at San Onofre Unit 3 on the letdown line exiting the Regenerative Heat Exchanger.
This failure was caused by excessive vibration on the piping line and is not an indlication of failure on the actual heat exchanger.
All of these welds and the nozzle inner radius section have received some type of nondestructive examination during inservice or preservice inspection. The pressure retaining welds on the Regenerative Heat Exchanger received preservice volumetric examinations as outlined in the attached table. Since the prcservice exams, visual VT-2 examinations have been performed in accordance with NRC approved relief requests. Some examinations were limited in coverage but these limitations would again create reduced coverage todlay. See Table 1 for Examination History.
V. PROPOSED ALTERNATIVE In accordance with the provisions of IOCFR50.55a(a)(3)(ii), approval is reqluested to use an alternative to the requirements in Table IWB 2500-1 for Categories B-B and B-D pertaining to the Regenerative Heat Exchanger and Table IWC 2500-1 for Categories C-A and C-B pertaining to the Residual and Relgenerative Heat Exchangers. Complying with the code required examination woluld result in hardship without a compensating increase in quality and safety due to excessive personnel radiation exposure and geometric examination difficulties. Specifically, a VT-2 examination will be performed as an acceptable alternative to the Code required examination.
V. PROPOSED ALTERNATIVE In accordance with the provisions of IOCFR50.55a(a)(3)(ii), approval is reqluested to use an alternative to the requirements in Table IWB 2500-1 for Categories B-B and B-D pertaining to the Regenerative Heat Exchanger and Table IWC 2500-1 for Categories C-A and C-B pertaining to the Residual and Relgenerative Heat Exchangers. Complying with the code required examination woluld result in hardship without a compensating increase in quality and safety due to excessive personnel radiation exposure and geometric examination difficulties. Specifically, a VT-2 examination will be performed as an acceptable alternative to the Code required examination.
Page 4 of 1 1 Serial No. 06-585 Docket No. 50-281 Attachment VI. DURATION OF PROPOSED ALTERNATIVE The use of this relief request is for the duration of the Surry Unit 2 Fourth Inservice Inspection Interval.
Page 4 of 1 1
VII. PRECEDENTS Sirnilar requests for relief were submitted and approved by the Nuclear Regulatory Commission for the Joseph M. Farley plant under TAC No. MA3449; North Anna Power Station Unit 2 under TAC No. MB07050; Surry Power Station Unit 1, third inservice inspection interval, under TAC No. MB1998; and Surry Power Station Unit 2, third inservice inspection interval under TAC No. MB1999. Page 5 of 11 Serial No. 06-585 Docket No. 50-281 Attachment SECTION A-A L~WER SUPPORT 's'mFEmF, I ,' ,2$F4a SECTION 8-8 UPPER SUPPORT
 
,875 THICKNESS  
Serial No. 06-585 Docket No. 50-281 Attachment VI. DURATION OF PROPOSED ALTERNATIVE The use of this relief request is for the duration of the Surry Unit 2 Fourth Inservice Inspection Interval.
.--/ EYIPlI8:LIL HEAO 4I. OD SEE YCllm A-A ASTM I-21. 1P 381 / ''O~r)l~ COUUECTIONS FOR NIRILSI ,875' TMICWfSS - 1311' PBB. LY. FLlL COlPLlUGl OJILEI DETAIL 1 '"5cH TUBE SID-E WELDS Figure 1 "A Residual Heat Exchanger Page 6 of 1 1 Serial No. 06-585 Docket No. 50-281 Attachment I &#xb6;F - INLET SECTION B-B UPPER SUPPORT rillPllClY HE0 42'00 SSE SECTION L-h ilSrH 6-248 TP 384 / '\LD.~,~ CDX(ECI,DYS Fa) WT.ILLI all). WIC<YFSI -' W1, 1BDB. 51 FLLL CDUPLlNGl prusr rm OUTLET DETAIL 1 'w5CH '' TUBE SIOEE WELOS Figure 2 "B" Residual Heat Exchanger Page 7 of 11 ELEVATION LOOKING WEST A Serial No. 06-585 Docket No. 50-281 Attachment SECTION 'B' SECTION 'A' Figure 3 Regenerative Heat Exchanger Page 8 of 11 Serial No. 06-585 Docket No. 50-281 Attachment Table 1 Examination History Component 1 Weld 1 Catlltem I Description I Exam Date I I I I I I I 2-RH-E-1 A 2-RH-E-1 A 2-RH-E-1 B I I I I 2-CH-E-3 11-18 1 B-BlB2.80 ( Tubesheet-to-Shell Weld 1 12/01/1971 1 -A01 1-A02 2-RH-E-1 B 2-CH-E-3 2-CH-E-3 2-CH-E-3 2-CH-E-3 1 -B01 Results! C-NC1.20 C-NC1.10 1-B02 1-04 1-1 7 1-19 1-03 2-CH-E-3 Comments 0" to 44" lndications dispositioned C-NC1.20 as geometrical.
VII. PRECEDENTS Sirnilar requests for relief were submitted and approved by the Nuclear Regulatory Commission for the Joseph M. Farley plant under TAC No. MA3449; North Anna Power Station Unit 2 under TAC No. MB07050; Surry Power Station Unit 1, third inservice inspection interval, under TAC No. MB1998; and Surry Power Station Unit 2, third inservice inspection interval under TAC No. MB1999.
Page 5 of 11
 
Serial No. 06-585 Docket No. 50-281 Attachment SECTION A-A L ~ W E RSUPPORT    's'mFEmF,       SECTION 8-8 UPPER SUPPORT I ,
                                                                                                      ' ,2$F4a OJILEI DETAIL 1 '"5cH TUBE SDI -E          WELDS
,875 THICKNESS .--/
EYIPlI8:LIL HEAO 4I. OD ASTM I-21.       1P 381
  ,875' T M I C W f S S -/ ''O~r)l~ COUUECTIONS 1311' P B B . L Y .
S E E Y C l l m A-A FOR NIRILSI FLlL COlPLlUGl Figure 1 " A Residual Heat Exchanger Page 6 of 11
 
Serial No. 06-585 Docket No. 50-281 Attachment I               &#xb6;F     -
INLET SECTION B-B UPPER SUPPORT prusr r m OUTLET DETAIL 1    'w5CH  ''
TUBE SIWELOS      OEE
                          /
rillPllClY                                       SSE SECTION L-h H E 0 42'00 ilSrH 6-248 TP 384         ' \ L D . ~ , ~ CDX(ECI,DYS   Fa) WT.ILLI all).W I C < Y F S I -
                        '             W1, 1BDB. 5 1 FLLL CDUPLlNGl Figure 2 "B" Residual Heat Exchanger Page 7 of 1 1
 
Serial No. 06-585 Docket No. 50-281 Attachment ELEVATION LOOKING WEST SECTION 'B'             SECTION 'A' A
Figure 3 Regenerative Heat Exchanger Page 8 of 11
 
Serial No. 06-585 Docket No. 50-281 Attachment Table 1 Examination History Component 1 I
I Weld 1 I
I Catlltem  I I
I Description        I I
Exam Date                Results!
Comments 2-RH-E-1A    1-A01     C-NC1.20       Head Circumferential Weld      03/06/1995  0" to 44" lndications dispositioned as geometrical.
44" to 88" No indications.
44" to 88" No indications.
88" to 0" 91 O/O coverage obtained, no indications.
88" to 0" 91OO/ coverage obtained, no indications.
0" to 44" lndications dispositioned as geometrical.
2-RH-E-1A    1-A02    C-NC1.10      Shell Circumferential Weld      03/6/1995  0" to 44" lndications dispositioned as geometrical.
44" to 66" No indications.
44" to 66" No indications.
Head Circumferential Weld Shell Circumferential Weld C-NC1.10 B-WB2.51 B-BlB2.51 B-BlB2.51 B-BlB2.80 1-22 88" to 0" No indications.
10/06/2003  88" to 0" No indications.
0" to 44" No indications.
2-RH-E-1B    1-B01    C-NC1.20      Head Circumferential Weld      10/1411986  0" to 44" No indications.
03/06/1995 03/6/1 995 Head Circumferential Weld 44" to 88" No Indications.
44" to 88" No Indications.
88" to 0" No indications, partial relief request SR-021 approved by 10/06/2003 10/1 411 986 Shell Circumferential Weld Circumferential Head Weld Circumferential Head Weld Circumferential Head Weld Tubesheet-to-Shell Welds B-BlB2.80  
88" to 0" No indications, partial relief request SR-021 approved by
~. NRC letter 94-271 . 22" to 44" No indications.
                                                                                                            ~.
10/14/1986 1 011 1/2000 0411 811 993 1 1/30/1971 12/01/1971 12/01/1971  
NRC letter 94-271.
2-RH-E-1B    1-B02    C-NC1.10      Shell Circumferential Weld      10/14/1986  22" to 44" No indications.
1011 1/2000 44" to 88" No indications.
0411811993  110" to 0" No indications.
2-CH-E-3      1-04      B-WB2.51      Circumferential Head Weld       11/30/1971              No indications.
2-CH-E-3      1-17      B-BlB2.51      Circumferential Head Weld       12/01/1971              No indications.
2-CH-E-3      1-19      B-BlB2.51      Circumferential Head Weld       12/01/1971              No indications.
2-CH-E-3      1-03      B-BlB2.80      Tubesheet-to-Shell Welds       12/01/1971  No indications. No coverage from 157" to 202" due to support bracket I        I              I                              I              and nozzle configuration.
2-CH-E-3  11-18    1 B-BlB2.80    ( Tubesheet-to-Shell Weld      1 12/01/1971  No indications. Limited coverage upstream due to pipe hanger.
2-CH-E-3      1-22      B-BlB2.80     Tubesheet-to-Shell Weld        11/30/1971  Baffle plate indication noted due to ID geometry.
Page 9 of 11
 
Serial No. 06-585 Docket No. 50-281 Attachment Component    I  Weld      Catlltem              Description          Exam Date                  Results/
I                                                                                  Comments B-DlB3.150    Nozzle-to-VesselWeld        12/01/1971      Indications due to ID geometry.
6-DIB3.150    Nozzle-to-Vessel Weld      12/01/1971      Indications due to ID geometry.
B-DlB3.150    Nozzle-to-VesselWeld        12/01/1971      Indications due to ID geometry.
B-DlB3.150    Nozzle-to-Vessel Weld      12/01/1971      Indications due to ID geometry.
6-DlB3.150    Nozzle-to-Vessel Weld      11/30/1971      Indications due to ID geometry.
B-DlB3.150    Nozzle-to-Vessel Weld      11/30/1971      Indications due to ID geometry.
C-NC1.20      Head Circumferential Weld  12/0111971      No indications. No coverage upstream side from 135" to 225"and downstream from 120" to 240" due to brace.
C-NC1.20      Head Circumferential Weld  12/01/1971      No Indications. No coverage upstream side from 135" to 225" and downstream side from 120" to 240" due to hanger.
C-NC1.20      Head Circumferential Weld  11/30/1971     No indications. 8OoA of downstream side could not be examined due to interference with support clamp and brace.
C-NC1.30        Tubesheet-to-Shell Welds    12/01/1971     No indications. No coverage on downstream side due to pipe hanger.
C-NC1.30        Tubesheet-to-Shell Welds    12/01/1971     No indications. No coverage downstream side from 157" to 202" due to support bracket.
C-NC1.30        Tubesheet-to-Shell Welds    11/30/1971      Indications due to ID geometry.
*Preoperational baseline UT examinations performed between November 1971 and November 1972.
Page 10 of 11


12/01/1971 44" to 88" No indications.
Serial No. 06-585 Docket No. 50-281 Attachment The following are Nozzle Inner Radius Sections and are not pressure retaining welds. All received satisfactory VT-2 exams in accordance with Relief Request SR-018 for the 2nd Interval and in accordance with Relief Request SR-029 for the 3rd Interval as shown.
1 10" to 0" No indications.
Component         Mark #          Catlltem        2nd Interval Exam Date      3rd Interval Exam Date 2-CH-E-3         NIR-06        B-DlB3.160              0311911995                    0610411996 2-CH-E-3         NIR-08        B-DlB3.160              0311911995                    06/04/1996 2-CH-E-3         NIR-09        B-DlB3.160              0311911995                    1012912000 2-CH-E-3         NIR-11       B-DlB3.160              0311911995                    1012912000 2-CH-E-3        NIR-13        B-DlB3.160               0311911995                    0411812002 2-CH-E-3        NIR-15        B-DlB3.160               0311911995                    0411812002 The following are reinforcing plate welds for the nozzle to vessel on the Residual Heat Removal Heat Exchanger and received surface examinations (liquid penetrant) as required by code on the dates shown:
No indications. Tubesheet-to-Shell Weld No indications.
Component        Mark #       Categorylltem    Method        Exam Date                        Results 2-RH-E-1A          1-A05        C-BlC2.31         PT          03/06/1995                    No Indications 2-RH-E-1A          1-A06        C-BlC2.31         PT          1012312003                    No Indications 2-RH-E-1A          1-A07        C-BlC2.3 1       PT          1011412003   Initial indication removed within acceptable grinding limits for grooming. No repair necessary. Evaluated by ET-CM-03-0025.
1 1/30/1971 No indications.
2-RH-E-1A          1-A08        C-BlC2.31        PT          1011512003  Initial indication found acceptable by volumetric acceptance criteria.
No indications.
2-RH-E-1B        1-B05          C-BlC2.31        PT          1012212003                    No indications 2-RH-E-1B        1-B06          C-BlC2.31        PT          1012212003                    No indications 2-RH-E-1B        1-807          C-BlC2.31        PT          1012412003 1 lnitial indication removed within acceptable    1 grinding limits for "grooming". No repair necessary. Evaluated by ET-CM-03-0025.
No coverage from 157" to 202" due to support bracket and nozzle configuration.
2-RH-E-1B        1-B08          C-BlC2.3 1        PT          1012412003  Initial indication removed within acceptable grinding limits for "grooming". No repair necessary. Evaluated by ET-CM-03-0025.
No indications. Limited coverage upstream due to pipe hanger. Baffle plate indication noted due to ID geometry.
Page I 1 of 11}}
Page 9 of 1 1 Serial No. 06-585 Docket No. 50-281 Attachment Component I Weld I Catlltem Description Exam Date Results/ B-DlB3.150 6-DIB3.150 B-DlB3.150 B-DlB3.150 6-DlB3.150 B-DlB3.150 C-NC1.20 C-NC1.20 C-NC1.20 C-NC1 .30 C-NC1.30 *Preoperational baseline UT examinations performed between November 1971 and November 1972.
Nozzle-to-Vessel Weld Nozzle-to-Vessel Weld Nozzle-to-Vessel Weld Nozzle-to-Vessel Weld Nozzle-to-Vessel Weld Nozzle-to-Vessel Weld Head Circumferential Weld Head Circumferential Weld Head Circumferential Weld Tubesheet-to-Shell Welds C-NC1.30 Page 10 of 11 Tubesheet-to-Shell Welds 12/01/1971 12/01/1971 12/01/1971 12/01/1971 1 1/30/1 971 1 1/30/1 971 12/01 11 971 12/01/1971 1 1/30/1971 12/01/1971 Tubesheet-to-Shell Welds Comments Indications due to ID geometry.
Indications due to ID geometry. Indications due to ID geometry.
Indications due to ID geometry.
Indications due to ID geometry. Indications due to ID geometry.
No indications.
No coverage upstream side from 135" to 225"and downstream from 120" to 240" due to brace. No Indications.
No coverage upstream side from 135" to 225" and downstream side from 120" to 240" due to hanger. No indications.
8OoA of downstream side could not be examined due to interference with support clamp and brace. No indications.
No coverage on downstream side due to pipe 12/01/1971 hanger. No indications.
No coverage downstream side from 157" to 202" 1 1/30/1971 due to support bracket. Indications due to ID geometry.
Serial No. 06-585 Docket No.
50-281 Attachment The following are Nozzle Inner Radius Sections and are not pressure retaining welds. All received satisfactory VT-2 exams in accordance with Relief Request SR-018 for the 2nd Interval and in accordance with Relief Request SR-029 for the 3rd Interval as shown. The following are reinforcing plate welds for the nozzle to vessel on the Residual Heat Removal Heat Exchanger and received surface examinations (liquid penetrant) as required by code on the dates shown: Component 2-CH-E-3 2-CH-E-3 2-CH-E-3 2-CH-E-3 2-CH-E-3 2-CH-E-3 Mark # NIR-06 NIR-08 N IR-09 NIR-11 NIR-13 NIR-15 Component 2-RH-E-1 A 2-RH-E-1 A 2-RH-E-1 A 2-RH-E-1 A 1012412003 1 lnitial indication removed within acceptable 1 2-RH-E-1 B 2-RH-E-1 B 2-RH-E-1 B Catlltem B-DlB3.160 B-DlB3.160 B-DlB3.160 B-DlB3.160 B-DlB3.160 B-DlB3.160 Mark # 1 -A05 1 -A06 1 -A07 1 -A08 Page I1 of 11 1 -B05 1 -B06 1-807 2-RH-E-1 B 2nd Interval Exam Date 0311 911 995 0311 911 995 0311 911 995 0311 911 995 0311 911 995 0311 911 995 Categorylltem C-BlC2.31 C-BlC2.31 C-BlC2.3 1 C-BlC2.31 3rd Interval Exam Date 0610411996 06/04/1996 1012912000 1012912000 0411 812002 0411 812002 C-BlC2.31 C-BlC2.31 C-BlC2.31 1 -B08 Method PT PT PT PT PT PT PT C-BlC2.3 1 Exam Date 03/06/1995 1012312003 1011412003 1011 512003 Results No Indications No Indications Initial indication removed within acceptable grinding limits for grooming.
No repair necessary.
Evaluated by ET-CM-03-0025. Initial indication found acceptable by 1012212003 1012212003 PT volumetric acceptance criteria.
No indications No indications 1012412003 grinding limits for "grooming".
No repair necessary.
Evaluated by ET-CM-03-0025. Initial indication removed within acceptable grinding limits for "grooming".
No repair necessary.
Evaluated by ET-CM-03-0025.}}

Revision as of 16:48, 23 November 2019

ASME Section XI Inservice Inspection Program Relief Request CMP-007 Regenerative and Residual Heat Exchangers
ML062090375
Person / Time
Site: Surry Dominion icon.png
Issue date: 07/27/2006
From: Gerald Bichof
Virginia Electric & Power Co (VEPCO)
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
06-585
Download: ML062090375 (14)
v • d • e


Text

VIRGINIA ELECTRIC AND POWER COMPANY RICHMOND, VIRGINIA2326 1 July 27, 2006 United States Nuclear Regulatory Commission Serial No.06-585 Attention: Document Control Desk NLOSlGDM R1 Washington, D.C. 20555 Docket No. 50-281 License No. DPR-37 VIRGINIA ELECTRIC AND POWER COMPANY SURRY POWER STATION UNIT 2 ASME SECTION XI INSERVICE INSPECTION PROGRAM RELIEF REQUEST CMP-007 REGENERATIVE AND RESIDUAL HEAT EXCHANGERS In a letter dated February 9, 2006 (Serial No.06-057), Virginia Electric and Power Company (Dominion) submitted Relief Request CMP-006, Revision 1, for Surry Power Station Unit 2 pertaining to ASME Section XI Code required inspections on the Regenerative and Residual Heat Exchangers. NRC approval was requested to use Code Case N-706, Alternative Examination Requirements of Table IWB-2500-1 and Table IWC-2500- 1 for PWR Stainless Steel Residual and Regenerative Heat Exchanger Section XI, Division 1, as an alternative to the requirements in Table IWB 2500-1 for Categories B-B and B-D pertaining to the Regenerative Heat Exchanger and Table IWC 2500-1 for Categories C-A and C-B pertaining to the Residual and Regenerative Heat Exchangers. However, it was subsequently determined that the Code Case requirement "All welds shall have received at least one volumetric examination ..." could not be met for certain components on the Residual and Regenerative Heat Exchangers in that a volumetric examination was never a code requirement. Consequently, verbatim use of Code Case N-706 was not possible for all of the subject items included in the relief request. Discussions were held with the ASME Code Case writers and verification was made that the intent of the Code Case was to cover all of these heat exchanger components. A revision to the Code Case is now in the approval process, which will provide alternative examination requirements for all of the components included in this relief.

During a subsequent telephone conference call with the NRC, Dominion agreed to submit a separate relief request that did not rely upon Code Case N-706 rather than waiting on approval of the Code Case revision. Therefore, pursuant to 10CFR50.55a(a)(3)(ii), approval is requested to use an alternative to the requirements in Table IWB 2500-1 for Categories 6-6 and B-D associated with the Regenerative Heat Exchanger and Table IWC 2500-1 for Categories C-A and C-B associated with the Residual and Regenerative Heat Exchangers for complying with the code required examination. Compliance with the code requirements would result in a hardship

Serial No.06-585 Docket No. 50-281 Page 2 without a compensating increase in quality and safety due to the excessive personnel radiation exposure that would result from the performance of the examinations, as well as the geometric difficulties that would be encountered. The specified alternative and its supporting basis are provided in attached Relief Request CMP-007. Relief Request CMP-007 supercedes in its entirety the previously submitted Relief Request CMP-006, Revision 1.

If you have any questions or require additional information, please contact Mr. Gary D.

Miller at (804) 273-2771.

Very truly yours,

.G. T. Bischof u Vice President - Nuclear Engineering Attachment Commitments made in the letter: None cc: U. S. Nuclear Regulatory Commission Region II Sam Nunn Atlanta Federal Center 61 Forsyth St., SW, Suite 23T85 Atlanta, Georgia 30303 Mr. S. R. Monarque U. S. Nuclear Regulatory Commission One White Flint North 11!j55 Rockville Pike Mail Stop 8H12 Rolckville, Maryland 20852 Mr. N. P. Garrett NR:C Senior Resident Inspector Surry Power Station Mr. R. A. Smith Authorized Nuclear Inspector Surry Power Station

Serial No.06-585 Docket No. 50-281 Attachment Relief Request CMP-007 Virginia Electric and Power Company (Dominion)

Surry Power Station Unit 2

Serial No.06-585 Docket No. 50-281 Attachment RELIEF REQUEST CMP-007

1. IDENTIFICATION OF COMPONENTS Various welds on the Residual (2-RH-E-1A and 2-RH-E-1B) and Regenerative Heat Exchangers (2-CH-E-3). The welds are:

Welds Descri~tion Cateaorv/ltem Class 1-A0 1 Head Circumferential Weld C-NC1.20 2 1-A02 Shell Circumferential Weld C-NC1.10 2 1-A05, 1-A06, Reinforcing Plate Welds to C-BlC2.31 2 1-A07,1 -A08 Nozzle and Vessel

- -

Welds Descri~tion Cateaorvlltem Class 1-E)01 Head Circumferential Weld C-NC1.20 2 1-E102 Shell Circumferential Weld C-A/C1 .I0 2 1-El05, 1-B06, Reinforcing Plate Welds to C-BlC2.31 2 1-ElO7, 1-BO8 Nozzle and Vessel Page 1 of 11

Serial No.06-585 Docket No. 50-281 Attachment Welds Descri~tion Cateaorvlltem Class 1-04, 1-17, Circumferential Head Welds B-BlB2.51 1

&l-19 1-03, 1-18, Tubesheet-to-Shell Welds B-BlB2.80 1

& 1-22 1-06, 1-08, Nozzle-to-Vessel Welds B-DlB3.150 1 1-09, 1-11, 1-13, & 1-15 NIR-06, NIR-08, Nozzle Inside Radius Section B-DlB3.160 NIR-09, NIR-11, NIR-13, & NIR-15 1-01, 1-21, Head Circumferential Welds C-NC1.20

& 1-24 1-02, 1-20, Tubesheet-to-Shell Welds C-NC1.30

& 1-23 II. APPLICABLE CODE EDITION AND ADDENDA Su~rryUnit 2 is currently in the Fourth lnservice Inspection Interval under the 1998 Edition through the 2000 Addenda of the ASME Section XI Code.

111. CODE REQUIREMENTS Examination Categories B-B, B-Dl from Table IWB-2500-1 and C-A, C-B from Table IWC-2500-1 require that volumetric or surface examinations be performed on the welds and nozzle inside radius areas listed above.

IV. BA.SISFOR RELIEF The subject welds are shown in Figures 1, 2 and 3 for stainless steel cornponents 2-RH-E-1A, 2-RH-E-1B and 2-CH-E-3, respectively.

Page 2 of 11

Serial No.06-585 Docket No. 50-281 Attachment The Regenerative Heat Exchanger (2-CH-E-3) provides preheat for the normal charging water flowing into the Reactor Coolant System (RCS). The Residual Heat Exchangers are designed to cool the RCS during plant shut down operations.

A feasibility study has been performed within the ASME and prepared by Westinghouse Owner's Group (WOG) project MUHP 5093, Working Group lnservice lnspection Optimization Action 97-01, ISI-03-06, BC03-338, "Technical Basis for Revision of lnspection Requirements for Regenerative and Residual Heat Exchangers", August, 2004. Technical justification for eliminating the surface and volumetric inspections of the Residual and Regenerative Heat Exlchangers is supported in this report. The components at Surry Power Station (i.~?.,

2-RH-E-1A and 1B; 2-CH-E-3) are typical of the heat exchangers described by fabrication, geometric design, inspection requirements and geometric restrictions.

As stated in the Westinghouse report, these components were designed and installed before the imposition of the inservice inspection requirements by Section XI and are not designed for performance of ultrasonic and surface examination. The small diameter of the vessel and nozzles of the Regenerative Heat Exchanger makes a meaningful ultrasonic examination very time consuming and dose intensive. The physical limitations would substantially diniinish the ability to discriminate flaw indications from geometry existing around the joint. Referring to the Residual Heat Exchangers, interference with the! lower support and interference with inlet and outlet pipes leads to only partial coverage for examination of the head and shell circumferential welds.

Furthermore, these components are located in high radiation fields. The estimated personnel dose to perform interval Code inspections on the Regenerative Heat Exchanger is 12.0 man-rem, and it is estimated that 4.5 man-renn would be required to meet the inspection requirements per interval for the Residual Heat Exchanger. In view of the significant dose required to be expended for limited examination providing questionable results, the value of performing the Code required examinations is minimal.

Two other factors presented in the Westinghouse report for these components were considered by the ASME committee - flaw tolerance and risk assessment.

Fracture evaluations were performed for the components using finite element models and fracture calculations. It was concluded that the heat exchangers have a large flaw tolerance and that significant leakage would be expected long before any failure occurred. Fatigue crack growth was determined to be extremely slow even in the most highly stressed region. Thus, detailed inspections are not required to ensure heat exchanger integrity.

Page 3 of 11

Serial No.06-585 Docket No. 50-281 Attachment A risk evaluation was performed using the accepted methodology applied for Risk Informed IS1 piping inspection programs. The following conclusions were made:

Safety equipment required to respond to the potential event is unaffected.

Potential for loss of pressure boundary integrity is negligible.

No safety analysis margins are changed.

Leakage before full break is expected (no core damage consequences associated with leakage).

Thus, elimination of the subject inspections would not be expected to result in a significant increase in risk.

There have been no through-wall leaks on these components or components of similar design as reported in industry and as discussed in the Westinghouse report. The only related leak in the United States occurred in January 2004 at San Onofre Unit 3 on the letdown line exiting the Regenerative Heat Exchanger.

This failure was caused by excessive vibration on the piping line and is not an indlication of failure on the actual heat exchanger.

All of these welds and the nozzle inner radius section have received some type of nondestructive examination during inservice or preservice inspection. The pressure retaining welds on the Regenerative Heat Exchanger received preservice volumetric examinations as outlined in the attached table. Since the prcservice exams, visual VT-2 examinations have been performed in accordance with NRC approved relief requests. Some examinations were limited in coverage but these limitations would again create reduced coverage todlay. See Table 1 for Examination History.

V. PROPOSED ALTERNATIVE In accordance with the provisions of IOCFR50.55a(a)(3)(ii), approval is reqluested to use an alternative to the requirements in Table IWB 2500-1 for Categories B-B and B-D pertaining to the Regenerative Heat Exchanger and Table IWC 2500-1 for Categories C-A and C-B pertaining to the Residual and Relgenerative Heat Exchangers. Complying with the code required examination woluld result in hardship without a compensating increase in quality and safety due to excessive personnel radiation exposure and geometric examination difficulties. Specifically, a VT-2 examination will be performed as an acceptable alternative to the Code required examination.

Page 4 of 1 1

Serial No.06-585 Docket No. 50-281 Attachment VI. DURATION OF PROPOSED ALTERNATIVE The use of this relief request is for the duration of the Surry Unit 2 Fourth Inservice Inspection Interval.

VII. PRECEDENTS Sirnilar requests for relief were submitted and approved by the Nuclear Regulatory Commission for the Joseph M. Farley plant under TAC No. MA3449; North Anna Power Station Unit 2 under TAC No. MB07050; Surry Power Station Unit 1, third inservice inspection interval, under TAC No. MB1998; and Surry Power Station Unit 2, third inservice inspection interval under TAC No. MB1999.

Page 5 of 11

Serial No.06-585 Docket No. 50-281 Attachment SECTION A-A L ~ W E RSUPPORT 's'mFEmF, SECTION 8-8 UPPER SUPPORT I ,

' ,2$F4a OJILEI DETAIL 1 '"5cH TUBE SDI -E WELDS

,875 THICKNESS .--/

EYIPlI8:LIL HEAO 4I. OD ASTM I-21. 1P 381

,875' T M I C W f S S -/ O~r)l~ COUUECTIONS 1311' P B B . L Y .

S E E Y C l l m A-A FOR NIRILSI FLlL COlPLlUGl Figure 1 " A Residual Heat Exchanger Page 6 of 11

Serial No.06-585 Docket No. 50-281 Attachment I ¶F -

INLET SECTION B-B UPPER SUPPORT prusr r m OUTLET DETAIL 1 'w5CH

TUBE SIWELOS OEE

/

rillPllClY SSE SECTION L-h H E 0 42'00 ilSrH 6-248 TP 384 ' \ L D . ~ , ~ CDX(ECI,DYS Fa) WT.ILLI all).W I C < Y F S I -

' W1, 1BDB. 5 1 FLLL CDUPLlNGl Figure 2 "B" Residual Heat Exchanger Page 7 of 1 1

Serial No.06-585 Docket No. 50-281 Attachment ELEVATION LOOKING WEST SECTION 'B' SECTION 'A' A

Figure 3 Regenerative Heat Exchanger Page 8 of 11

Serial No.06-585 Docket No. 50-281 Attachment Table 1 Examination History Component 1 I

I Weld 1 I

I Catlltem I I

I Description I I

Exam Date Results!

Comments 2-RH-E-1A 1-A01 C-NC1.20 Head Circumferential Weld 03/06/1995 0" to 44" lndications dispositioned as geometrical.

44" to 88" No indications.

88" to 0" 91OO/ coverage obtained, no indications.

2-RH-E-1A 1-A02 C-NC1.10 Shell Circumferential Weld 03/6/1995 0" to 44" lndications dispositioned as geometrical.

44" to 66" No indications.

10/06/2003 88" to 0" No indications.

2-RH-E-1B 1-B01 C-NC1.20 Head Circumferential Weld 10/1411986 0" to 44" No indications.

44" to 88" No Indications.

88" to 0" No indications, partial relief request SR-021 approved by

~.

NRC letter 94-271.

2-RH-E-1B 1-B02 C-NC1.10 Shell Circumferential Weld 10/14/1986 22" to 44" No indications.

1011 1/2000 44" to 88" No indications.

0411811993 110" to 0" No indications.

2-CH-E-3 1-04 B-WB2.51 Circumferential Head Weld 11/30/1971 No indications.

2-CH-E-3 1-17 B-BlB2.51 Circumferential Head Weld 12/01/1971 No indications.

2-CH-E-3 1-19 B-BlB2.51 Circumferential Head Weld 12/01/1971 No indications.

2-CH-E-3 1-03 B-BlB2.80 Tubesheet-to-Shell Welds 12/01/1971 No indications. No coverage from 157" to 202" due to support bracket I I I I and nozzle configuration.

2-CH-E-3 11-18 1 B-BlB2.80 ( Tubesheet-to-Shell Weld 1 12/01/1971 No indications. Limited coverage upstream due to pipe hanger.

2-CH-E-3 1-22 B-BlB2.80 Tubesheet-to-Shell Weld 11/30/1971 Baffle plate indication noted due to ID geometry.

Page 9 of 11

Serial No.06-585 Docket No. 50-281 Attachment Component I Weld Catlltem Description Exam Date Results/

I Comments B-DlB3.150 Nozzle-to-VesselWeld 12/01/1971 Indications due to ID geometry.

6-DIB3.150 Nozzle-to-Vessel Weld 12/01/1971 Indications due to ID geometry.

B-DlB3.150 Nozzle-to-VesselWeld 12/01/1971 Indications due to ID geometry.

B-DlB3.150 Nozzle-to-Vessel Weld 12/01/1971 Indications due to ID geometry.

6-DlB3.150 Nozzle-to-Vessel Weld 11/30/1971 Indications due to ID geometry.

B-DlB3.150 Nozzle-to-Vessel Weld 11/30/1971 Indications due to ID geometry.

C-NC1.20 Head Circumferential Weld 12/0111971 No indications. No coverage upstream side from 135" to 225"and downstream from 120" to 240" due to brace.

C-NC1.20 Head Circumferential Weld 12/01/1971 No Indications. No coverage upstream side from 135" to 225" and downstream side from 120" to 240" due to hanger.

C-NC1.20 Head Circumferential Weld 11/30/1971 No indications. 8OoA of downstream side could not be examined due to interference with support clamp and brace.

C-NC1.30 Tubesheet-to-Shell Welds 12/01/1971 No indications. No coverage on downstream side due to pipe hanger.

C-NC1.30 Tubesheet-to-Shell Welds 12/01/1971 No indications. No coverage downstream side from 157" to 202" due to support bracket.

C-NC1.30 Tubesheet-to-Shell Welds 11/30/1971 Indications due to ID geometry.

  • Preoperational baseline UT examinations performed between November 1971 and November 1972.

Page 10 of 11

Serial No.06-585 Docket No. 50-281 Attachment The following are Nozzle Inner Radius Sections and are not pressure retaining welds. All received satisfactory VT-2 exams in accordance with Relief Request SR-018 for the 2nd Interval and in accordance with Relief Request SR-029 for the 3rd Interval as shown.

Component Mark # Catlltem 2nd Interval Exam Date 3rd Interval Exam Date 2-CH-E-3 NIR-06 B-DlB3.160 0311911995 0610411996 2-CH-E-3 NIR-08 B-DlB3.160 0311911995 06/04/1996 2-CH-E-3 NIR-09 B-DlB3.160 0311911995 1012912000 2-CH-E-3 NIR-11 B-DlB3.160 0311911995 1012912000 2-CH-E-3 NIR-13 B-DlB3.160 0311911995 0411812002 2-CH-E-3 NIR-15 B-DlB3.160 0311911995 0411812002 The following are reinforcing plate welds for the nozzle to vessel on the Residual Heat Removal Heat Exchanger and received surface examinations (liquid penetrant) as required by code on the dates shown:

Component Mark # Categorylltem Method Exam Date Results 2-RH-E-1A 1-A05 C-BlC2.31 PT 03/06/1995 No Indications 2-RH-E-1A 1-A06 C-BlC2.31 PT 1012312003 No Indications 2-RH-E-1A 1-A07 C-BlC2.3 1 PT 1011412003 Initial indication removed within acceptable grinding limits for grooming. No repair necessary. Evaluated by ET-CM-03-0025.

2-RH-E-1A 1-A08 C-BlC2.31 PT 1011512003 Initial indication found acceptable by volumetric acceptance criteria.

2-RH-E-1B 1-B05 C-BlC2.31 PT 1012212003 No indications 2-RH-E-1B 1-B06 C-BlC2.31 PT 1012212003 No indications 2-RH-E-1B 1-807 C-BlC2.31 PT 1012412003 1 lnitial indication removed within acceptable 1 grinding limits for "grooming". No repair necessary. Evaluated by ET-CM-03-0025.

2-RH-E-1B 1-B08 C-BlC2.3 1 PT 1012412003 Initial indication removed within acceptable grinding limits for "grooming". No repair necessary. Evaluated by ET-CM-03-0025.

Page I 1 of 11

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